Information-sharing and data-protection protocol
The terms under which competing banks, insurers and critical-infrastructure operators exchange information during a joint executive crisis exercise. Published so that legal, compliance and data-protection functions can review it before their executives take part.
1. Purpose and scope
This protocol governs the exchange of information between organisations taking part in a joint executive crisis exercise on this platform. It covers the exercise itself, the facilitator console, the debrief, and any cross-organisation analysis derived from a session.
It does not govern real-incident information sharing. Exercise participation creates no obligation, and no channel, for sharing live incident intelligence between participants.
4. Attribution rule
Sessions run under a modified Chatham House Rule. Inside the session room, decisions are attributed so that participants can see who diverged and discuss it.
Outside the session, participants may use the substance of what was discussed but may not attribute a decision, statement or weakness to another named organisation or individual without that organisation's written consent.
Exported artefacts — PDF debriefs, scorecards and shareable links — carry this restriction on their face.
5. Legal basis and personal data
Personal data processed is limited to what participation requires: name, business email, organisation, executive role, and exercise decisions. The legal basis is the legitimate interest of the participating organisations in joint crisis preparedness (GDPR Art. 6(1)(f)), or the contract with the participating organisation where one exists (Art. 6(1)(b)).
No special-category data is collected. No profiling with legal or similarly significant effect is performed: exercise scores are a training instrument and must not be used as an input to employment decisions.
Participants may request access, correction or erasure of their personal data at any time. Erasure removes the individual's identity from the record; anonymised aggregate scores already computed may be retained.
6. Competition-law guardrails
Joint exercises between competing institutions are limited to operational resilience and crisis response. Pricing, commercial terms, customer allocation, market strategy and any other commercially sensitive parameter are out of scope, and facilitators are instructed to stop discussion that moves toward them.
Scenario options are written so that no realistic path requires disclosure of commercially sensitive information.
7. Retention and deletion
Live session rooms and their real-time state expire automatically 24 hours after creation.
Cohort submissions, debrief results and corrective actions are retained for the duration of the programme and for 24 months afterwards, so that a retest can be compared with the original run.
A participating organisation may request deletion of its own submissions at any time; the shared aggregate is then recomputed without them.
8. Access control
Participant access is by individual invitation token or by an approved access request. Facilitator and administrative functions require a separate facilitator credential or an administrator account.
Row-level access rules restrict every organisation to its own records; cross-organisation analysis is produced server-side and released only in the agreed aggregate form.
External stakeholder seats — supervisor, regulator, law enforcement, provider, auditor — are invited explicitly by the facilitator for a named session and see only that session.
9. Participation undertaking
Before a cohort session, each participating organisation confirms: it accepts this protocol; it will not attribute another participant's decisions externally without consent; it will not introduce real incident, customer or production data into the exercise; and it accepts that exercise results are indicative planning material, not assurance, certification or a prediction of real-incident performance.
The confidentiality and ethics gate inside the platform records that confirmation before a participant can enter a shared room.